Comments on the Draft New London Plan

Our organisation represents residents in two council wards at the outer northern edge of the Borough of Barnet. The area is typified by streets of terraced and semi-detached family houses. Flats are few, maximum four storeys, except around High Barnet town centre and along main roads.

At the London Forum meeting on 29 January Mr Richards said that, inter alia, the Plan would ‘preserve and enhance the most valued features’. We wish to challenge this statement in the context of suburban housing. Here in our area the most valued feature is the presence of family houses, the major distinction between inner London and the suburbs. The Plan is not only failing to offer any protection for this housing, it is actively encouraging wholesale replacement with smaller properties

We do recognise there are many positive features to the Plan. Whilst we might quibble with some of the detail we are so dismayed by POLICY H2 that we have decided to base this whole submission on that, with added comments on TRANSPORT POLICY, but only on the context of H2 and how this relates to the impact of additional housing likely to be created through H1 and H2.

Availability of development sites

A key feature of the Plan is for 40% (26,000) of the target of 66,000 homes a year to come from small sites. The target here is based on a projection that the identified trends of recent years will be maintained. We strongly doubt this. Many of the new homes on small sites have come from brownfield land, former light industrial locations, conversion of offices to flats and, increasingly, the demolition or conversion of large houses to create flats or smaller houses, plus some ‘back garden’ development. For the future the Mayor is (rightly in our view) proposing to curtail the loss of employment through the conversion of offices and closure of industrial sites, and has said the Green Belt remains sacrosanct. Developers have trawled and trawled again to find vacant plots of land to build on and such sites have largely dried up. So what is left? Intensification in town centres has proceeded apace (rooms above shops to flats and extra floors, though we acknowledge this still has some way to go). But otherwise what is left has to be the conversion or replacement of the existing housing stock to greater density.

Small sites

We accept the thrust of Policy H1 which seeks to identify surplus sites currently used for a variety of purposes that may be changed to housing, though we believe opportuities will be increasingly limited. But draft Policy H2 (small sites) is where new potential sites might be found, and reveals the true extent of the threat to suburban houses. Existing streets are faced with wholesale changes to their character through additional housing and increases in density (H2B1). This will be achieved by conversions, extensions, infill, demolition and redevelopment (H2D2).

The policy is said to apply over an area close to transport hubs and within 800m of a town centre, which may appear restrictive but in reality is nearly everywhere.

Such defence of the existing stock as there is will be limited to ensuring ‘good design’ (in our experience a nonsensical concept), concerns about loss of privacy for neighbours, protecting houses for ‘large families’ (not defined) and protecting heritage assets. These are very thin defences indeed.

The intent is clear – a massive change to the existing suburban housing stock of family homes by replacement with the creation of many more flats or at best very small houses.

The character of the suburbs

This intention runs counter to the aspirations of people living in the suburbs, many of whom have moved to such areas from more central locations wishing to substitute a house for a flat, which they believe is the right environment for bringing up children able to have a bedroom each, enjoy the facility and safety of a garden, and be able to take a complex range of journeys in a family car.

Housing aspirations of families

There is a strong desire for space. With the effects of stamp duty and restricted supply of larger houses we have had a vast increase in domestic extensions. The figures are telling. In the past year alone in High Barnet, a ward of some 6000 homes, we have had planning applications for some 160 extensions. Add in extensions under ‘permitted development’ rules, which we believe total at least as many again, and we have had over 300 extensions in just one year. This is a trend that has been running for many years. There has not been a commensurate increase in population as these extensions largely just reflect a desire for an existing family to enjoy more habitable space. Against this evident trend the notion that better-off families will in future tolerate living in two-bedroom properties (Policy H12) is nonsensical.

Existing pressures on family homes and their protection

Also over the past year in High Barnet ward we have had some 50 applications to convert or demolish houses or other buildings, or to build on back gardens, in order to create small blocks of flats or several small houses. In the town centre such planning applications have generally succeeded with little opposition, but in areas characterised by streets of houses such applications have been strongly contested by neighbours who fear a fundamental loss to their quality of life. Many of these applications have failed because at the moment the Local Plan offers a strong defence by identifying that conversion will be resisted in areas characterised by family homes. If this defence is removed redevelopment applications will soar.

Smaller homes

Almost all the new build or conversions in recent years have been to create small homes – the majority studio or one-bedroom flats. We are sensing a weakening in demand for such properties, which in part may reflect the reluctance of families or better-off people to accept the limitations of such accommodation, and what we perceive to be a desire on the part of younger people to live more centrally than in the ‘boring’ suburbs.

Car usage

There is a presumption in the Plan that reliance on the car will significantly reduce. Again the reality of how the suburbs tick is either not recognised or deliberately ignored. There is no analysis of car journeys compared to the extensive analysis of public transport use. Someone living 800 metres from a town centre might be able to travel to and from the centre without a car, but for most residents travel is far more complex than just one route. The vast numbers of cars travelling out of our borough to work, and the equally vast numbers travelling in are testament to that. The public transport service is far too thin in outer areas to support complex journeys in the same way that they can be undertaken in inner areas. The road network in the outer suburbs is already saturated in many places and it is unrealistic to believe that additional homes will not generate more traffic, and there is no provision to provide road capacity to accommodate more.

Public transport provision

For travel to central London many suburban areas such as ours are being offered almost nothing by way of improved public transport: a stark contrast to the major initiatives such as the Elizabethan Line. Even without changes to the housing stock there has been an increasing trend of local employment giving way to many more people travelling to central London to work. The High Barnet branch of the Northern line is already identified as overcrowded and may become impossible if we build the number of additional homes in its catchment area as envisaged by the plan.

A plan for conflict by forcing unwanted changes on the suburbs

In the sections above we have highlighted where the Plan is deficient in recognising the reality of suburban life and aspirations and how its objectives as drafted run counter to the expectations of suburban residents.

To achieve what the Plan envisages we are faced with nothing less than a major project in social re-engineering, whether intended or not, with the character of large areas of the suburbs changing from ’suburban’ to ‘urban’. Our impression is that the authors of the draft Plan have viewed the entire issue through a Central London filter, with little understanding of what makes the suburbs tick or what the obstacles to realising their vision might be. At the moment the residents of the suburbs are wholly unaware of what may be about to happen to them, but there will unquestionably be a backlash as major proposals for change start to take effect in their streets. Better-off families may flee London in droves to seek a more agreeable environment in the Home Counties.

The existing suburban family houses make an invaluable contribution to the mix of housing available on London, reflecting the aspirations of many thousands of Londoners, and as such should be protected. Largely restricting housing options to flats or small houses may make sense in central London but it will run counter to the reality of suburban life. If the door is opened to wholesale degrading of this housing stock it is London that will ultimately be the loser as families seek more agreeable pastures.

Likely failure and ways to avoid it

We are in no doubt that adopted as written the Plan will be a disaster – either it will fail in the face of objections from the suburbs or if implemented as we fear it might the result will ultimately not be to the benefit of London as a whole. We urge a major re-think of the Plan in relation to housing in the outer suburbs and in particular ask that the following be considered:

Recognise that the essential character of the suburbs is very different to Inner London. The Plan should reflect how the suburbs function and what the aspirations of the residents are. Only with such an understanding should the Plan then seek to secure the consent of residents for change.

Limit the encouragement of intensification to an area much less than 800m around town centres – we consider 200m would be more appropriate, or even better, simply retain the existing PTAL categories.

Recognise that the streets of Victorian and Edwardian terraces of family houses are highly valued and offer quality sought-after characterful accommodation with strong density levels. All such housing where family homes still predominate should be protected against redevelopment or conversion.

Targets for additional homes for areas within Boroughs should be set at levels which reflect the ability of the transport network to accommodate more people, taking account of the reality of continued reliance on cars and the very patchy proposals for significant improvements to public transport in many outer areas.